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OFAC FAQ (Current) # 803 - Executive Order of August 5, 2019, “Blocking Property of the Government of Venezuela”

Date issued: Nov. 05 2019

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803. What types of activity does General License 35 authorize?

U.S. persons are authorized to engage in certain administrative transactions with the Government of Venezuela that are prohibited by E.O. 13884 of August 5, 2019, where such transactions are necessary and ordinarily incident to such persons’ day-to-day operations. General License 35 authorizes U.S. persons to pay taxes, fees, and import duties to the Government of Venezuela, and to purchase or receive permits, licenses, registrations, certifications, and public utility services from the Government of Venezuela, so long as these transactions are necessary and ordinarily incident to such persons’ day-to-day operations.

U.S. persons should remain cautious when engaging in authorized activity with blocked persons to ensure all criteria for use of the general license are met. The illegitimate former Maduro regime has a long history of corruption, and we encourage U.S. persons who rely on the authorization in General License 35 to exercise appropriate due diligence to ensure compliance with the terms of the authorization. The U.S. government will continue to target corruption by the illegitimate former Maduro regime. As with any general or specific license, OFAC is prepared to revoke this authorization if appropriate to support U.S. foreign policy and national security priorities. [11-05-2019]
External link location:
https://ofac.treasury.gov/faqs/803

TURBOFAC Commentary (120 words)

Notes:

1) Among sanctions programs involving blocked governments, Venezuela GL 35 is unique, and appears to represent a substantial softening of the effects of the blocking of the Government of Venezuela (GOV). With respect to the portion of the FAQ stating "we encourage U.S. persons who rely on the authorization in General License 35 to exercise appropriate due diligence to ensure compliance with the terms of the authorization," OFAC is presumably concerned primarily with ensuring that no transactions involve persons blocked pursuant to Venezuela-related authorities other than EO 13884. Meanwhile, the meaning of "day to day" is a difficult interpretative question that OFAC has not addressed in the Venezuela context. Refer to Venezuela GL 35, and comments thereto.